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Tower Heist

<h1 class="h2">Privacy policy </h1>

<h2 class="h3">Introduction </h2>

We are <a id="_Hlk19011171"></a>StarzPlay US, LLC ("Starz", "us", "our" or "we"). We provide the Lionsgate+ subscription service (the "Service"). 

This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing the Service. This policy also provides contact details and important information about privacy rights. 

We explain the Service in more detail in the Terms of Use. Please read this policy together with our Terms of Use <a id="_Hlk19011188"></a><a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/br/en/termsofuse">https://www.lionsgateplus.com/br/en/termsofuse</a>.

This policy was last updated 1/23/2023. We will periodically update this policy so please check back for updates. 

<h2 class="h3">What personal data do we collect?</h2>

We collect personal data relating to subscribers of the Service and other authorized users ("Subscribers") when they interact with the website associated with the Service, any mobile or TV app associated with the Service and/or any of the features or downloads that we make available through the Service. We also collect personal data relating to other individuals that interact with the Service, such may be website visitors or individuals who view our service via their device or profile. 

Specifically, we collect the following types of personal data relating to Subscribers and other individuals – 

<ul>
 <li>Name and address.</li>
 <li>CPF (Natural Persons Register).</li>
 <li>Date of birth.</li>
 <li>Contact details (including email address and phone number).</li>
 <li>Registration, username, password, password reminder and other information relating to “User Accounts” (as defined in the Terms of Use <a id="_Hlk19011579"></a><a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/br/en/termsofuse">https://www.lionsgateplus.com/br/en/termsofuse</a>.</li>
 <li>Payment details (in limited circumstances).</li>
 <li>Registration for any contests, features and other promotions offered as part of, or in relation to, the Service. </li>
 <li>Participation in online research.</li>
 <li>Reports of issues with the Service. </li>
 <li>Correspondence (including email and chat).</li>
 <li>Screen names. </li>
 <li>Submissions, voting and polling activities.</li>
 <li>Service usage and activity.</li>
 <li>Search queries.</li>
 <li>Information about interests. </li>
 <li>Social media accounts and use. </li>
 <li>Third party access to the Service (for example, access via Facebook login).</li>
 <li>Technology used to access the Service, including –</li>
 <li>Device information.</li>
 <li>Browser information. </li>
 <li>Internet service provider or mobile carrier.</li>
 <li>Referring and exit pages.</li>
 <li>Date and time stamps.</li>
 <li>Clickstream data (including page clicks and scrolls).</li>
 <li>Location.</li>
 <li>Bandwidth speed.</li>
 <li>Software and registry keys.</li>
 <li>IP address and device ID.</li>
 <li>Information from cookies and similar technologies.</li>
</ul>
 
In addition to collecting personal data directly from Subscribers and other individuals, we collect information from social media companies as well as other companies with whom Subscribers and other individuals have a relationship (“Partners”). Partners include Internet Service Providers, third parties that distribute the Service, online and offline data providers and voice assistant platform providers. We recommend that Subscribers and other individuals read the privacy policies of all organisations that process personal data relating to them. 

<h2 class="h3">How we use personal data</h2>

We use personal data of the categories under lit. a-q above to provide, promote and develop the Service. More specifically we use personal data to –

<ul>
 <li>Improve the Service by providing personalized content, language, help and instructions </li>
 <li>Customize the Service by location.</li>
 <li>Provide customer service assistance.</li>
 <li>Ask Subscribers to participate in surveys, products, services, news and events.</li>
 <li>Provide Subscribers with news, newsletters, updates, targeted advertising, promotions, sweepstakes and special offers. </li>
 <li>Better understand how Subscribers use the Service (including checking traffic patterns and what types of content are most popular).</li>
 <li>Receive and respond to submissions or correspondence. </li>
 <li>Use Subscriber submissions in accordance with the Terms of Use <a id="_Hlk19011728"></a><a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/br/en/termsofuse">https://www.lionsgateplus.com/br/en/termsofuse</a> for the Service. </li>
 <li>Administer community postings (for example, chat and bulletin boards), including publishing screen names and other information provided by Subscribers on the Internet or elsewhere. </li>
 <li>Repost comments about the Service, programmes and/or content on various online platforms and social media (for example, Twitter). </li>
 <li>Check email *opens*.</li>
 <li>Exercise and comply with legal rights.</li>
</ul>

<h2 class="h3">Our legal grounds to use personal data</h2>

By accepting the Terms of Use and this Policy, you give us your free, informed and express consent for collecting, processing and using your personal data, for the purposes described in this Policy, recognizing also that all relevant and necessary information regarding such data processing is contained in this document. For any additional or specific functionalities of the Services (for example, for advertising cookies or new features), we will request additional consent from you in a clear manner, after giving you all relevant information about that feature or functionality.

	Necessary for the performance of a contract 
Where we use personal data to provide the Service to Subscribers or to otherwise perform our obligations and exercise our rights under the Terms of Use <a id="_Hlk19011902"></a><a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/br/en/termsofuse">https://www.lionsgateplus.com/br/en/termsofuse</a>, aside from the consent you have given to us, this processing is also necessary for the performance of a contract with the Subscriber. 

 Legitimate interests 
Where we use personal data relating to individuals with whom we do not have a contract for the purposes of the Service, our legal ground is that doing so is necessary for the legitimate interest of operating and progressing our business. 

Similarly, where we use personal data relating to Subscribers outside the Terms of Use for the <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/br/en/termsofuse">https://www.lionsgateplus.com/br/en/termsofuse</a> purposes of the Service (for example, the development and promotion of the service), our legal ground is that doing so is necessary for the legitimate interest of providing, developing and promoting our business. 

Where we send Subscribers emails (or other electronic messages) containing promotional material about the Service, our legal ground is that doing so is for necessary for the purposes of the legitimate interest of promoting our business.

Sometimes, we may use personal data if necessary for a third party's legitimate interest. Where required and appropriate, we or the third party will provide you with more information about any such legitimate interest.


Importantly, we will not use personal data on the grounds of a legitimate interest where the relevant individual or Subscriber's rights and freedoms override the legitimate interest. In addition, where we rely on a legitimate interest to use personal data, the individual or Subscriber to whom the personal data relates may object. To object please contact us at <a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a>. 

Exercise of legal rights
We will also use personal data in establishing, exercising or defending our legal rights. 

 
 
 Legal obligations 
Separately from providing, developing and promoting the Service, we will also use personal information when we are required to do so by law. Where that is the case, aside from the consent you have given to us, our legal ground for this processing is also that such use of personal data is necessary to comply with a legal obligation.

<h2 class="h3">Consequences of not providing personal data</h2>

Subscribers are required to provide registration, contact and payment details in order to access the Service. We will not be able to provide the Service to Subscribers that do not provide this information. 

<h2 class="h3">Automated decision-making</h2>

We use automated decision-making to provide Subscribers with the most relevant content and develop the Service. However, we do not use automated decision-making to make any legally significant decisions about individuals.

<h2 class="h3">Sharing personal data</h2>

Social media 
Subscribers and other individuals may engage with the Service through third-party social networks (for example, Facebook, Twitter and Pinterest). We may also allow Subscribers to access their accounts or specific content through social networks. Where Subscribers or other individuals engage or login through social media, we will share personal data with and receive personal data from the relevant social network. Where Subscribers or individuals engage or login through a social network, we recommend they read the relevant social network's privacy policy. 

 Partners
We share personal data with and receive personal data from Partners.

 Service providers 
To help provide, develop and promote the Service, we share personal data with and receive personal data from the following types of service provider – 

<ul>
 <li>Distributors.</li>
 <li>Payment processors.</li>
 <li>Fraud and credit risk service screening providers.</li>
 <li>Advertising partners.</li>
 <li>Analytics service providers. </li>
 <li>IT providers. </li>
 <li>Professional services (for example, accountants and lawyers). </li>
</ul>

We have contracts in place with these service providers that strictly govern how they may use the personal data (listed above lit-a-q) we share with them.

Group companies and business reorganizations 
We will share personal data (listed above lit. a-q) with our group companies where necessary to provide, develop or promote the service. 

We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Starz and/or the Service. 

 Legal rights and obligations 
We will share personal data where necessary to establish, exercise or defend our legal rights. 

We will also share personal data where required by the courts, regulators or law. 

<h2 class="h3">Cookies and similar technologies</h2>
 
Cookies 
Cookies are small information files that we place on the devices used to access the Service. The types of Cookies we use are described below:

 Essential Cookies. Our sites and services won’t work properly without Essential cookies. For example, We and our Service Providers may use Essential to identify and authenticate subscribers. We also use essential cookies to enforce our Terms of Use, maintain the security of our sites and services.
 Performance Cookies. Performance cookies collect information about how visitors use our sites and services, for example, which pages users visit most often and error messages received by users from web pages. Performance cookies don’t collect information that identify a visitor and the information these cookies collect is aggregated and anonymized.
 Advertising Cookies. Advertising cookies are used to deliver advertisements relevant to visitors based on the visitor’s interests and to measure the effectiveness of advertising campaigns. These cookies are usually placed by advertising networks with our permission. They remember that you have visited the website and this information is shared with other organizations such as advertisers.

 Embedded scripts 
An embedded script is a programming code used to collect information about how Subscribers use the Service. The embedded script is temporarily downloaded onto devices used to access the Service. The embedded script is only active whilst the device is used to access the Service.

 Web beacons 
A web beacon is a small graphic image or programming code that is included in some parts of the Service. 

 Advertising 
We, and selected third-party advertising partners, use cookies, embedded scripts and web beacons to present adverts through the Service. Our advertising partners may also employ other similar types of technologies.

We have not implemented a response to browser-based Do Not Track signals. 

For more information about advertising and your ability to opt-out of targeted advertising from such third parties, please visit the Network Advertising Initiative (www.networkadvertising.org) and/or the Self-Regulatory Program for Online Behavioral Advertising (www.aboutads.info/choices).

Analytics 
We, and selected analytics service providers, use cookies, embedded scripts and web beacons to provide analytical information about the Service. Our analytics service providers may also employ other similar types of technologies.

 Consent 
Where we need to seek consent for analytics and advertising cookies, embedded scripts, web beacons and other similar technologies, we will let you know. 

<h2 class="h3">Children </h2>

We do not knowingly collect or use any personal data relating to individuals under the age of 13 – except if necessary on a one-time basis in response to a specific issue. If you are a parent or guardian that has discovered that your child under 13 has submitted personal data without your permission, please contact us immediately at <a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a>. 

<h2 class="h3">International transfers </h2>

We routinely transfer personal data from Brazil to the European Economic Area ("EEA"), the United States and other regions. Where we transfer personal data to EEA, the United States and other regions we will always guarantee security and confidentiality of the transferred personal data or approved standard contractual clauses safeguards. You agree and consent the transfer of your personal data and if you would like more information about how we transfer personal data outside and the safeguards we use, please contact us at privacy@lionsgateplus.com.

<h2 class="h3">Data retention </h2>

We keep personal data relating to a Subscriber until the end of the end of their subscription. We will only keep personal data relating to a Subscriber after their subscription where necessary to exercise our legal rights and fulfil our legal obligations. 

<h2 class="h3">Rights</h2>

In accordance with the applicable Brazilian legislation, Subscribers and other individuals have the rights to – 

<ul>
 <li>Information about how we use personal data (which is what this policy is for).</li>
 <li>Access to personal data.</li>
 <li>Object to direct marketing and the use of personal data based on the grounds of legitimate interest.</li>
 <li>Erasure of personal data.</li>
 <li>Portability of personal data.</li>
 <li>Withdraw consent where our use of personal data is based on consent.</li>
 <li>Rectification of personal data.</li>
 <li>Restriction of personal data. </li>
 <li>Confirmation of processing personal data</li>
 <li>Information about the sharing with public and private entities.</li>
</ul>

Please note that the Account Management section of the Service provides access to a broad range of payment, contact and account information (including the content you have viewed and rated). You may access further information or exercise the other rights listed above using the contact details below. 

Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or they are not relevant. 
Exercising Your Rights 
Exercising Your Rights. To submit a request to know, delete, or opt-out, please visit <a class="hyperlink" href="https://submit-irm.trustarc.com/services/validation/7c11ddc5-703e-4661-ba8c-85ef940aa717" target="_blank" rel="noreferrer">Lionsgate+ Privacy Rights Manager</a>.
<h2 class="h3">Contact</h2>

If you need assistance with any of the issues covered in this policy and are unable to resolve your question via the "Help" feature of the Service, please contact us at <a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a>.

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